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PA Bulletin, Doc. No. 19-192



PACE Expansion of the Living Independence for the Elderly Program to Multiple Counties

[49 Pa.B. 686]
[Saturday, February 9, 2019]

 Living Independence for the Elderly (LIFE) Program is the Commonwealth's program under the Federal Program of All-inclusive Care for the Elderly (PACE). The Department of Human Services (Department) is planning to expand the LIFE Program to serve additional counties to satisfy participant needs and interest. The Department's goal is to have LIFE services available across all of this Commonwealth. The Department will solicit information from organizations interested in serving one or more of the following counties: Carbon, Monroe, Pike, Wayne, Susquehanna, Bradford, Sullivan, Tioga, Potter, Cameron, Elk, Jefferson, Clearfield, Centre and Fulton.

 LIFE providers will be responsible to deliver specific services to individuals enrolled in the LIFE Program who are eligible for Medical Assistance (MA) and are nursing facility clinically eligible. To become a LIFE provider, the organization must be enrolled in the MA Program, comply with Federal PACE regulations and adhere to the related PACE program agreements.

 The Department will not provide any grant dollars or other payment for the initial development of a LIFE Program. Organizations responding to this notice (Responders) will be responsible for all costs both incurred to respond to this request and incurred in subsequent approval and development processes. The Department will not authorize enrollment of participants until: the PACE program agreements between the provider, the Centers for Medicare and Medicaid Services (CMS) and the Department have been signed; the selected Responder has executed an MA Provider Agreement; and the Commonwealth budget includes an allocation that is sufficient to support this expansion.

 The Responder shall provide an electronic copy on a new USB drive and one original hard copy of the submission to the Department within 60 days of this publication. In addition, the Responder may submit a redacted copy of the submission for proprietary purposes.

Submission Requirements

 The Responder must include in the submission the following and in the order listed. The Responder must label all documents clearly. A response from a partnership must be a single, unified document.

1. Cover Letter

 An officer of the Responder authorized to contractually bind the organization shall submit a signed cover letter which commits to starting LIFE services within 18 months of notification by the Department. This letter should clearly specify the county or counties for which the Responder wishes consideration. Responders interested in more than one county shall rank each county in order of interest from most desirable to least desirable. For partnerships, a letter detailing a joint commitment to serve the area(s) is required from an officer of each partner.

2. Organizational Background

 The Responder shall illustrate its history and experience and the experience of any parent organization in serving individuals qualified for the PACE program and in developing long-term services and supports projects. The Responder shall also identify each of the members of its corporate governing board, their responsibilities and their relationship to any parent organization. It shall identify the proposed management team for the proposed project.

 Each Responder, its parent corporation and (if applicable) other PACE programs associated with the Responder shall be in good standing with the Department and CMS.

 Responders shall provide copies of any reports, penalties or restrictions issued for a period of 2 years prior to the date of this notice by CMS, the Department or other governmental agencies on any PACE Provider Organization associated with the Responder. The Responder gives the Department the right to contact CMS, any other state's PACE administrator and other governmental agencies in regard to the Responder's performance. The Department must be satisfied that any deficiencies have been, or are being, corrected and that the deficiency is unlikely to recur.

3. Feasibility Study

 The Responder shall provide the Department with a feasibility study (including a market and financial assessment) of the project showing the number of PACE-eligible citizens in the service area and the expected growth of enrollment by month for at least the first 2 years of operation. The study must be conducted by an approved PACE Technical Assistance Center which can be found at The Responder shall provide a complete copy of the study or the submission will be rejected.

 The feasibility study must address at least the following and provide evidence and examples to support any claims:

 • The realistic demand for the PACE services in the proposed service area. The analysis must cite the sources and years of the data used, the calculations and rationale to estimate the PACE-eligible population, and must provide comparison to successful PACE programs in similar regions, Nationally or in this Commonwealth. The analysis cannot assume that the program will achieve substantial market penetration in the early years or be a market leader, that is reaching 15-16%, without substantial proof.

 • The Responder's experience in programs having principles consistent with the PACE model, and the Responder's depth of leadership and experience required to address the challenges in developing a sustainable PACE program.

 • The Responder's experience with primary, acute or long-term care services and demonstrated capability in serving a Medicare and Medicaid-eligible population.

 • The financial capacity to fund program development, assume financial risk and fund risk reserve to and through the sustainability point. This shall include a 2- year start-up budget showing the following:

 a) Monthly enrollment growth projections.

 b) Costs of operations, including marketing and advertising.

 c) Sources of funding, both initial start-up and periodic infusions.

 d) The break-even census number and month, plus the desired maximum census.

 • A project design that incorporates a new or existing LIFE center and describes the service plan and staffing ratios at or above PACE best practices. The project design must also describe transportation for the participants and 24-hour service capability.

 • The Responder's accessibility to nursing facilities, home and community-based services, hospitals and other needs of this population.

4. Service Area

 Responders shall describe the service area (by zip codes or county boundaries, or both), the estimated number of PACE-eligibles, geography, demographics and the realistic annual enrollment expected over the first 2 years. A map showing travel times to the LIFE center and to critical health care and other contracted facilities should be included.

5. Marketing Plan

 Responders shall illustrate the outreach methods, the advertising methods and schedules, and follow-up schedules. Responders shall also illustrate and document any contracts and commitments that are already in place with aging organizations, medical and service providers, community leaders and the like (examples: marketing professionals on staff who have successfully started and sustained a PACE-like program; uniqueness in project design or outcomes expected; eliminating or downsizing nursing facility beds; improving the quality of collaborations with hospitals, personal service and medical providers, housing sources and builders; and incorporating innovative referral and marketing methods).

6. Implementation Plan

 Responders shall show an ability to provide services to potential participants within 18 months of receiving formal notification of selection from the Department. Details of the implementation plan shall include the level of construction needed for the site and whether a design firm or contractor has been consulted and provide the firm(s) names for projects that include a new LIFE center. Responders shall describe the staffing plan and whether a set of professionals and others has been surveyed for interest in serving the program. The implementation plan shall also explain how operational needs will be managed 24 hours a day. Further, the selected Responder must adhere to milestones established by the Department. The Department will terminate a project which is not executed in a timely manner. The Department will not authorize participant enrollment until the PACE program agreements between the provider, CMS and the Department have been signed, an executed MA Provider Agreement is in place and the Commonwealth budget allocation is sufficient to support this expansion. Responders are responsible for ensuring all PACE program agreements are signed and a Medicaid provider enrollment has been successfully completed.

7. Financial Viability and Commitment

 Responders shall provide realistic, justified and attainable detailed financial projections (including resources for consulting, acquisition of space, acquisition of equipment, vans, working capital and solvency reserves), and enrollment census projections for at least 2 years. If applicable, the Responder shall provide evidence that the organization has been successful with similar operations. The Responder shall provide a letter of commitment from the board of directors, signed by an officer of the organization authorized to contractually bind the organization, to fund the project through the break-even point. In addition, the Responder shall provide documentation of a risk reserve that will provide for sustainability. The Responder shall provide the last 2 years of audited financial statements. If external financing is needed, provide a letter of intent from the lender.

Evaluation of Submissions

 The Department will evaluate the responses. The Department reserves the right to investigate any claims made or information provided. The Department also reserves the right of final approval or to reject a submission or to modify and reissue this solicitation. If selected, the Responder will be required to complete additional steps, such as submission of a formal CMS application.

 Partnering in submissions is allowable; however, each Responder must provide a letter of commitment authorized by their board of directors, which is signed by an officer of the organization authorized to contractually bind the organization. Partnering in a submission does not limit an organization's ability to submit independently. Partnership responses must be submitted as a single submission, address the entire county and have clear definitions of the partners' responsibilities. Partners share responsibility for serving the entire county (or a defined portion), although each shall cover a unique service area. The LIFE participants in each area must receive equal quality, quantity and variety of services. The proposal must contain commitments from each partner that, if a partner falters or becomes financially unstable, the other(s) will absorb that service area and serve those participants. Submittals not describing the entire county and committing to a specific area will be rejected.

Fiscal Impact

 There is no fiscal impact anticipated in Fiscal Year (FY) 2018-2019. The fiscal impact for FY 2019-2020 and subsequent years cannot be determined at this time. The fiscal impact will be limited to the amount permitted by the funds appropriated by the General Appropriations Act for the fiscal year.

Submission of Information

 Submissions must be provided on a new USB drive and in one hard-copy binder. The USB drive submission must be in text-searchable PDF format, except for maps and audited financial information. The submission must be addressed to the Department of Human Services, Office of Long-Term Living, Office of Chief of Staff, Attention: Jonathan Bowman, P.O. Box 8025, Harrisburg, PA 17105-8025. The Department must receive the submission within 60 days of this publication or the submission will be rejected. Questions regarding this notice should be submitted to the Department at

 Persons with a disability who require an auxiliary aid or service may submit questions using the Pennsylvania AT&T Relay Service at (800) 654-5984 (TDD users) or (800) 654-5988 (voice users).


Fiscal Note: 14-NOT-1310. No fiscal impact; (8) recommends adoption.

[Pa.B. Doc. No. 19-192. Filed for public inspection February 8, 2019, 9:00 a.m.]

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